Ricketts v. Scothorn, 57 Neb. 51, 77 N.W. 365 (1898) provides an example of a contract without consideration, enforced on grounds of reliance. "Having intentionally influenced the plaintiff to alter her position for the worse on the faith of the note being paid when due, it would be grossly inequitable to permit the maker, or his executor, to resist payment on the ground that the promise was given without consideration."

Feinberg v. Pfeiffer Co., 322 S.W.2d 163 (Mo. App. 1959) and Ricketts v. Scothorn are detrimental reliance cases. The latter is closer to the example in the book. The plaintiff's grandfather had made a promise to her but, after his death, his executor refused to honor it; the court held for the plaintiff.